It may seem strange to conduct a mock survey in an assisted living facility. For one, there’s no impact on 5-star ratings since those ratings don’t exist in assisted living. Furthermore, citation fines aren’t as punitive or costly as they are for nursing homes. Even citation language is softer: nursing homes are “deficient” while assisted living facilities have “insufficiencies” in their care.
However, while CMS and state surveyors might not scrutinize assisted living to the same extent as nursing homes, quality of care is equally important in both settings. Mock surveys are one of the most underutilized tools to enhance care and manage litigation risk.
Mock Surveys Alleviate Stress on Administrators
I’ve worked in the long term care industry for four decades as an administrator, director of nursing, and assisted living regional operations director, so I know that caring for residents is at the heart of what we do. I’ve also seen that assisted living directors wear multiple hats every day: attending to resident and family concerns, filling in when staffing needs arise, dealing with employee concerns, and all sorts of other immediate “fires.” Assisted living directors simply don't have the time to take multiple days to conduct their own internal survey of operations to prepare for state surveyors.
That’s why partnering with a mock survey provider can be beneficial. Mock survey consultants are focused on one thing only: spending three to five dedicated days identifying a community’s opportunities for improvement and working with directors and staff to create action plans to address weaknesses and liabilities.
Mock Surveys Are a Critical Liability Risk Management Tool
Even without the impact on CMS ratings, assisted living facilities still need to consider their liability risk and how much of the risk the facility owns. While punitive fines do not exist as often in assisted living, the major risk is to be out of substantial compliance. For facilities that do not fully know their weaknesses and vulnerabilities, a mock survey is the perfect time to figure these out rather than during the actual state survey.
With our current staffing crisis, there seems to be turnover at every level, from resident care assistants to directors. With that amount of turnover, it is easy for staff to be unfamiliar—or worse, unaware—of policies and procedures to ensure resident safety. Assisted living communities can be held liable for inadequate hiring practices or negligence when staff are not trained or supervised, and incidents occur. Mock surveys provide an opportunity to have an outside consultant evaluate how well staff are trained and implement procedures that get all staff on the same page.
Mock Surveys Are Important in a Post-COVID World
We know that COVID has dramatically shifted the health care landscape. During the height of the pandemic, state surveys were paused or focused primarily on COVID management. With the advent of the vaccines, life has essentially returned to normal in assisted living and surveys have resumed as usual. However, the major change is the increased focus on infection control practices. To be frank, infection control practices were not stressed enough pre-pandemic since assisted living focused more on hospitality than on medical care. Now, we are seeing better outcomes for residents with medical issues like urinary tract infections or falls as we have more medical awareness and can take a more proactive approach to care. However, these efforts require staff training and formal procedures; initiatives that can be reviewed and addressed in a mock survey to ensure medical services are integrated optimally within the assisted living hospitality model.
How Mock Surveys Can Specifically Help Assisted Living Communities
As a former administrator myself, I know that assisted living leadership are worried all the time. The stress of knowing if you will have enough staff, whether residents are receiving all they need to age successfully, trying to optimize occupancy rates in a competitive environment, and negotiating rising costs for labor, food, and supplies is draining. That’s why I believe that one of the primary benefits of mock surveys is peace of mind and confidence. Mock surveys take the vital signs of the facility and help administrators prioritize what they need to be concerned about. Administrators are constantly putting out fires, and mock survey consultants help facilities identify the actual and hidden fires to help teams focus and prioritize.
After decades of performing mock surveys for long term care facilities, I know the difference mock surveys make. For new facilities or facilities with new administrators, a mock survey sets the team and facility up for success. I’ve also worked with some facilities for more than a decade, and mock surveys are a tool in their toolbox to decrease stress for administrators and drive effective operations. With a mock survey, I spend hours on-site being a resource for over-stressed administrators to identify vulnerabilities, both known and unknown, and help teams prioritize where to focus on quality improvement.
Everyone in our field has the same challenge: staffing. Year after year, I visit the same facility, and it’s rare that the same people are in charge. With constant turnover, assisted living facilities do not have the time for a brand-new director to spend multiple days getting up to speed and preparing for a survey. In contrast, as a mock survey consultant, I dedicate my time at each facility to over-prepare their staff for the survey. With a mock survey, I identify the vulnerabilities of the assisted living facility and establish systems that can be implemented easily, even when there is a revolving door of staff. I focus on the paperwork so administrators can work with the people.
There are limited organizations to call on for assistance with how policy changes affect a particular assisted living because there are no national regulations for assisted living. Not understanding how to implement new state policies puts facilities at risk for non-compliance citations. In my work, I use assisted living mock survey templates specific to each state. That way, as a consultant, I can ensure I know the regulations of each specific state, can speak to the specific trends happening in that geographic area, and can be a resource for a facility’s particular needs.
Growing up, both of my grandmothers lived with me so all I’ve ever known is how to work with “old” people. And that’s a common refrain I hear from others in our industry: the commitment to helping people live out their later years in the best way possible. Our promise is to care for the residents in our communities. Being a faithful steward of that mission should drive us to seek solutions to provide the utmost quality of care. Participating in mock surveys is evidence of living that mission and being truly invested in the quality of your facility and serving your residents.
Leann Miller is a nurse consultant for Polaris Group. She has over 40 years of experience as a health care administrator and assisted living director. She holds a degree in Healthcare Administration, is a certified Dementia Specialist, and is certified in sub-acute care by the American College of Health Care Administrators.